The complaint in this case adequately alleged loss causation based on a stock price drop after the New York Post ran an article about BofI revealing, based on information it obtained through FOIA requests, that the SEC was investigated BofI for money laundering. The article was close enough to a contradiction of BofI’s denial of knowledge of any investigation. The fact that the Post obtained the information through a FOIA request did not show that the information was publicly available before the Post obtained it. FOIA requests have to be made and the requested information provided before it becomes available to the requester or the public. On the other hand, an Internet post by a short seller who claimed to rely on publicly available information and performed no analysis that the average stock buyer could not perform on his own was not the kind of public revelation of new information that could be used to prove loss causation.